SUPPORTING STATEMENT ENVIRONMENTAL PROTECTION AGENCY
NESHAP for Off

- Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal) 1. Identification of the Information Collection 1(a) Title of the Information Collection NESHAP for Off

- Sit e Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal) , EPA I CR Number 1717.07, OMB Control Number 2060

- 0313 1(b) Short Characterization/Abstract The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Off

- Site Waste an d Recovery

Operations were proposed on October 13, 1994, and promulgated on July 1, 1996. These standards apply to hazardous air pollutant (HAP) emissions from selected facilities involved in waste management and recovery o perations that are not subject t o Federal air standards under other subparts in part 63, and commencing construction, modification or reconstruction after the date of proposal if the facility is a major source of HAP emissions, as defined in general provisions to 40 CFR part 63. In addi tion, subpart DD cross

- references control requirements to be applied to specific ty

pes of affected sources: tanks

- level 1; containers; surface impoundments; individual drain systems; oil

- water separators; organic water separators; and loading, transfer, and storage systems. This information is being collected to assure compliance with 40 CFR part 63, subpart DD. Organic HAP emissions are the pollutants regulated under this subpart. Owners or operators of the affected facilities described must make one

- ti me - only notifications. Owners or operators are also required to maintain records of the occurrence and duration of any

startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. S emiannual reports of excess emissions, or reports certifying that no exceedances have occurred, are required. These notifications, reports, and records are essential in determining compliance; and, in general, are required of all sources subject to the NESHAP. Any owner or operator subject to the provisions of this part shall maintain a file of these measurements, and retain the file for at least five years following the date of such measurements, maintenance reports, and records. All reports are sent to the delegated state or local authority . In the event that there is no such delegated authority, the reports are sent directly to the United States Environmental Protection Agency (EPA) regional office. There is an annual average of 236 respondent s that will be subject to the regulations. Due to the nature of the industry, it is estimated that no additional sources will become subject to the standard over the next three years. This information is based on discussions with EPA personnel knowledgea

ble about the off

- site waste and recovery

operations. The average annual cost to2

industry over the next three years of this Information Collection Request (I CR) is estimated to be $14,681,368. The Office of Management and Budget (OMB) approved the currently active I CR without any “Terms of Clearance.” The burden to the “Affected Public” may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Off

- Site Waste and Recovery O perations (40 CFR part 63, subpart DD) (Renewal) . The burden t o the “Federal government” is attributed entirely to work performed by Federal employees or government contractors. This burden may be found below in Table 2: Average Annual EPA Burden

- NESHAP for Off

- Site and Waste Recovery Operations (40 CFR part 63, s ubpart DD) (Renewal)

. 2. Need for and Use of the Collection 2(a) Need/Authority for the Collection The EPA is charged under section 112 of the Clean Air Act, as amended, to establish standards of performance for each category or subcategory

of major s ources and area sources of hazardous air pollutants. These standards are applicable to new or existing sources of HAP and shall require the maximum degree of emission reduction. Ina ddition, section 114(a) states that the Administrator may

require any

owner or operator subject to any requirement of this Act to: (A) Establish and maintain such records; (B) make such reports; (C) install, use, and maintain such monitoring equipment, and use such audit procedures, or methods; (D) sample such emissions (in accordance with such procedures or methods, at such locations, at such intervals, during such periods, and in such manner as the Administrator shall prescribe); (E) keep records on control equipment parameters, production variables or other indirect data when direct monitoring of emissions is impractical; (F) submit compliance certifications in accordance with Section 114(a)(3); and (G) provide such other information as the Administrator may reasonably

require.
Inthe Administrator's judgment, HAP em issions from off

- site waste and recovery operations cause or contribute to air pollution that may reasonably

be anticipated to endanger public health or welfare. Therefore, the NESHAP was promulgated for this source category at 40 CFR part 63, subpart DD. 2(b) Practical Utility/Users of the Data The control of emissions of pollutants from off

- site waste and recovery

operations requires not only the installation of properly d esigned equipment, but also the operation and maintenance of that equipment. Em issions of organic HAP from off

- site waste and recovery

operations are the3

result of operation of the affected facilities. The subject standards are achieved by the reduction of organic HAP emissions using control technology and/or leak detection and repair procedures. The notifications required in the applicable regulations are used to inform the Agency or delegated authority

when a source becomes subject to the requirements of the regulations. The reviewing authority

may then inspect the source to chec k if the pollution control devices are properly i nstalled and operated, that leaks are being detected and repaired, and that the regulations are being met. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations. The information generated by the monitoring, recordkeeping and reporting requirement described in this I CR is used by the Agency

to ensure that facilities affected by the NESHAP continue to operate the control e quipment in compliance with the regulation. A dequate monitoring, recordkeeping, and reporting are necessary to ensure compliance with the applicable regulations, as required by

the Clean Air Act. The information collected from recordkeeping and reporting requirements is also used for targeting inspections, and is of sufficient quality to be used as evidence in court.
3. Non
- duplication, Consultations, and Other Collection Criteria The requested recordkeeping and reporting are required under 40 CFR part 63, subpart DD. 3(a) Non
- duplication If the subject standards have not been delegated, the information is sent directly to the appropriate EPA regional office. Otherwise, the information is sent directly to the delegated state or local agency
. If

a s tate or local agency

h as adopted their own similar standards to implement the Federal standards, a copy of the report submitted to the state or local agency can be sent to the Administrator in lieu of the report required by the Federal standards. Therefore, no duplication exists. 3(b) Public Notice Required Prior to ICR Submission to OMB An announcement of a public comment period for the renewal of this IC R was published in the Federal Register (74 FR 38004) on July 30, 2009. No comments were received o n the burden published in the Federal Register

. 3(c) Consultations Over the next three years, an average of 236 facilities per year will be subject to the standard, with no additional sources per year becoming subject to the standard. We have also determined that approximately 33 percent of the respondents are reporting electronically . In estimating the affected number of sources and the growth rate of off

- site waste and recovery operations facilities subject to this standard during a previous renewal, we contacted the Solid Waste Association of North America (SWANA) Ms. Shannon Crawford, at (800) 467

- 9262, and4

Chartwell Information, Mr. Grant Ferrier, (619) 295

- 7685. For this renewal, we contacted Environmental Business International (formerly Chartwe ll Information), Mr. Grant Ferrier, (619) 295

- 7685, who did not refute current estimates. We referenced the most recent I CR, and used other resources to obtain the most recent data available. We reviewed information available from the Online Tracking Inf

ormation System (OTI S) which is the primary source of information regarding the number of existing sources. OTI S data was used in conjunction with industry consultation to verify

the number of sources and the industry growth rate. 3(d) Effects of Less Frequent Collection Less frequent information collection would decrease the margin of assurance that facilities are continuing to meet the standards. Requirements for information gathering and recordkeeping are useful techniques to ensure that good operation and maintenance practices are applied and emission limitations are met. I f the information required by these standards was collected less frequently, the likelihood of detecting poor operation and maintenance of control equipment and noncompliance wo uld decrease. 3(e) General Guidelines None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5. These standards require affected facilities to maintain all records, inc luding reports and notifications for at least five ye ars. This is consistent with the General Provisions as applied to the standards. E PA believes that the five

- ye ar records retention requirement is consistent with the P art 70 permit program and the five

- ye ar statute of limitations on which the permit program is based. Also, the retention of records for five ye ars would allow EPA to establish the compliance history o f a source and any

pattern of compliance for purposes of determining the appropriate leve l of enforcement action. Historically, EPA has found that the most flagrant violators frequently have violations extending beyond the five years. EPA would be prevented from pursuing the worst violators due to the destruction or nonexistence of records i f records were retained for less than five ye ars. 3(f) Confidentiality The required information has been determined not to be confidential. However, any information submitted to the Agency for which a claim of confidentiality is made will be safeguarde d according to the Agency policies set forth in title 40, chapter 1, part 2, subpart B

- Confidentiality

of Business Information (CBI) (see 40 CFR 2; 41 FR 36902, September 1, 1976; amended by

43 FR 40000, September 8, 1978; 43 FR 42251, September 20, 1978 ; 44 FR 17674, March 23, 1979). 3(g) Sensitive Questions None of the reporting or recordkeeping requirements contain sensitive questions.5

4. The Respondents and the Information Requested 4(a) Respondents/SIC Codes The respondents to the recordkeepin g and reporting requirements are off

- site waste and recovery operations that store, treat, recycle, reprocess, or dispose of wastes containing organic chemical compounds. The United States Standard Industrial Classification (SI C) codes, which correspond t o the North American Industry Classification System (NAI CS) codes, could be found in the following table:
Off
- site Waste and Recovery Operations (40 CFR part 63,

subpart DD) SIC Codes NAICS Codes Petrochemical Manufacturing 2869 325110 All Other Basic Inorganic Chemical Manufacturing 2869 325188 Cyclic Crude and Intermediate Manufacturing 2689 325192 Ethyl Alcohol Manufacturing 2689 325193 All Other Basic Organic Chemical Manufacturing 2689 325199 In dustrial Gas Manufacturing 2689 325120 All Other M iscellaneous Chemical Product and Preparation Manufacturing 2689 325998 Plastic Materials and Resin Manufacturing 2821 325211 Explosives Manufacturing 2892 325920 Carbon Black Manufacturing 2816 325182 In organic Dye and Pigment Manufacturing 2816 32513 1 Semiconductor and Related Device Manufacturing 3674 334413 Petroleum Refineries 2911 324110 Aircraft Manufacturing 3721 336411 Aircraft (research and development not producing prototy pes) 3721 541710 Other General Government Support 9199 921190 All Other Petroleum and Coal Products Manufacturing 3312 324199 Iron and Steel Mills 3312 331111 Rolled Steel Shape Manufacturing 3312 331221 4(b) Information Requested None of these reporting or recordkeeping requirements violate any of the regulations established by

OMB at 5 CFR part 1320, section 1320.5.6 (i) Data Items All data in this I CR that is recorded and/or reported is required by National Emission Standards for Hazardous Air Pollutants for Off

- Site Waste and Recovery Operations (40 CFR par

t 63, subpart DD). A source must make the following reports:

Reports for 40 CFR part 63, subpart DD Notification and application of construction/reconstruction 63.5(d) Notification of initial startup 63.9(b) Notification of initial performance test 63 .7(b) and 63.9(e) Rescheduled initial performance test 63.7(b)(2) Demonstration of continuous monitoring system 63.9(g) Compliance status 63.9(h) Physical and operational change 63.10 Notification of performance tests 63.7(b), and 63.697(b)(1) Perfor mance test results 63.8(e)(5), and 63.697(b)(2) Startup, shutdown, malfunction reports 63.697(b)(3) Notification of tank floating roof inspection 63.686(b)(3) Notification of oil/water separator floating roof inspection 63.687(d)(6) Notification to tank refill 63.697(d)(1) Notification of seal gap measurements 63.697(d)(2) Reports In itial performance test results 63.10(d)(2) Opacity or visible emissions 63.10(d)(3) Periodic startup, shutdown, malfunction reports 63.10(d)(5)(i) Source status repor

t 63.10(e)(3) Excess emission reports 63.695(e) Semiannual summary

report 63.697(b)(4) A source must keep the following records:

Recordkeeping for 40 CFR part 63, subpart DD Startup, shutdown, malfunctions, periods where the continuous monitoring sys tem is inoperative. 63.10(b)(2) All reports and notifications. 63.10(b) Record of applicability

. 63.10(b)(3) Records of sources with continuous monitoring systems. 63.10(c)7 Recordkeeping for 40 CFR part 63, subpart DD Records of startup, shutdown, and malfunctions, and pollution control system maintenance. 63.696(b)(1) Records of applicability

determinations. 63.696(b)(3) Documentation of extension of tank emptying schedule. 63.696(c) Records of results of seal gap measurements and description of repairs. 63.686(d)(3) Record of sampling plan f or determining volatile organic hazardous air pollutant (VOHAP) concentration at point of treatment 63.694(c) Record of sampling plan for determining maximum HAP vapor pressure in tanks. 63.694(j)(2)(1) Record of maximum HAP vapor pressure determinations for covered tanks 63.686(c)(5) Records should be retained for 5 years. 63.10(b)(1) Electronic Reporting Currently, sources are using monitoring equipment that provides parameter data in an automated way, e.g., leaks and spills of mercury . Although personnel at the source still need to evaluate the data, this ty

pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. In addition, some regulatory agencies are setting up electronic reporting systems t o allow sources to report electronically which is reducing the reporting burden. H owever, electronic reporting systems are still not widely u sed by the regulatory agencies. Iti s estimated that approximately 3 3 percent of the respondents use electronic reporting. (ii) Respondent Activities

Respondent Activities Determine the VOHAP concentration for off

- site material at the point

- of

- delivery and for the treated off

- site material streams at the point

- of

- treatment. Determine the required HAP mass removal rate, actual HAP mass removal, HAP reduction efficiency and HAP bio

- degradation efficiency

. Determine the maximum organic HAP vapor pressure of the off

- site material in tanks and the process vent stream flow rate and total HAP concentration. Write the notifications and reports listed above. Enter information required to be recorded above. Submit the required reports developing, acquiring, installing, and utilizing technology and systems for the purpose of collecting, validating, and verifying information. Develop, acquire, install, and utilize technology and systems for the purpose of processing and maintaining information. Develop, acquire, install, and utilize technology and systems for the purpose of disclosing and providing information. Train personnel to be able to respond to a collection of information.8 Respondent Activities Adjust existing ways to comply with any previously

applicable instructions and requirements. Transmit, or otherwise disclose the information. Currently, sources are using monitoring equipm ent that provides parameter data in an automated way, e.g., HAP vapor pressure. Although personnel at the source still need to evaluate the data, this ty

pe of monitoring equipment has significantly reduced the burden associated with monitoring and recordkeeping. 5. The Information Collected: Agency Activities, Collection Methodology, and Information Management 5(a) Agency Activities
EPA conducts the following activities in connection with the acquisition, analysis, storage, and distribution of the req uired information.

Agency Activities Observe initial performance tests and repeat performance tests if necessary

. Review notifications and reports, including performance test reports, excess emissions reports, startup, shutdown, malfunction plan, and qu ality control plan for CMS required to be submitted by industry

. Audit facility

records. Input, analy

ze, and maintain data in the Air Facility System (AFS). 5(b) Collection Methodology and Management Following notification of startup, the reviewing a uthority might inspect the source to determine whether the pollution control devices are properly i nstalled and operational. Performance test reports are used by

the Agency

to discern a source’s initial capability to comply

with the emission standard, and note the operating conditions under which compliance was achieved. Data and records maintained by the respondents are tabulated and published for use in compliance and enforcement programs. The semiannual reports are used for problem identification, as a check on source operation and maintenance, and for compliance determinations.
In formation contained in the reports is entered into the AFS which is operated and maintained by

the EPA Office of Compliance. AFS is the EPA database for the collection, mai ntenance, and retrieval of compliance and annual emission inventory data for more than 100,000 industrial and government

- owned facilities. EPA uses the AFS for tracking air pollution compliance and enforcement by l ocal and state regulatory agencies, EPA regional offices and EPA headquarters. EPA and its delegated Authorities can edit, store, retrieve and analy ze the data. The records required by

this regulation must be retained by the owner or operator for five ye ars.9

5(c) Small Entity Flexibility
A ma jority of the affected facilities are primarily small entities (e.g., small businesses). According to the Off

- Site W aste and Recovery Operations NESHAP: Economic Impact Analysis,. (EPA

- 452/R

- 96

- 011, June 1996), EPA specifically identified 388 firms that o wn 621 potentially affected facilities. These 388 firms include 110 small businesses that own 112 facilities Therefore, this IC R assumes approximately 1 8 percent of the total facilities are small businesses, or 42 of 236 respondents. The impact on small entities was taken into consideration during the development of the regulation. Due to technical considerations involving the process operations and the ty pe of control equipment employed, the recordkeeping and reporting requirements are the same for both small and large entities. The Agency considers these requirements the minimum needed to ensure compliance and, therefore, cannot reduce them further for small entities. 5(d) Collection Schedule The specific frequency

f or each information collection ac tivity w ithin this request is shown below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Off

- Site Waste and Recovery Operations (40 CFR part 63, subpart DD) (Renewal)

. 6. Estimating the Burden and Cost of the Collection Table 1 documents the computation of individual burdens for the recordkeeping and reporting requirements applicable to the industry for the subpart included in this I CR. The individual burdens are expressed under standardized headings believed to be consistent with the concep t of burden under the Paperwork Reduction Act. Wherever appropriate, specific tasks and major assumptions have been identified. Responses to this information collection are mandatory

. The Agency

may not conduct or sponsor, and a person is not required t o respond to, a collection of information unless it displays a currently valid OMB Control Number. 6(a) Estimating Respondent Burden The average annual burden to industry over the next three years from these recordkeeping and reporting requirements is e stimated to be 155,212 (Total L abor Hours from Table 1). These hours are based on Agency studies and background documents from the development of the regulation, Agency

knowledge and experience with the NESHAP program, the previously approved I CR, and any comments received. 6(b) Estimating Respondent Costs (i) Estimating Labor Costs This I CR uses the following labor rates:10 Managerial $114.49 ($54.52 + 110%) Technical $98.20 ($46.76 + 110%) Clerical $48.53 ($23.11 + 110%)
These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilian Workers, by Occupational and Industry group.” The rates are from column 1, “Total compensation.” The rates have been increased by 110 percent to account for the benefit packages available to those employed by private industry

. (ii) Estimating Capital/Startup and Operation and Maintenance Costs The capital/startup costs are one - time costs when a facility b ecomes subject to the standard. Since this is bas ed on no new sources over the next three years, capital/startup costs associated with this I CR during this period will be zero. In addition, there is no significant operation and maintenance costs associated with this I CR since sources are not required to install continuous monitoring systems. The only operational cost that sources will incur is associated with photocopying and postage which would be minimal based on a rate of $7.57 per response. There are approximately

708 responses per year (708 respon ses x $7.57 = $5,359.56), for a total annual operation and maintenance (O&M) cost of $5,360. 6(c) Estimating Agency Burden and Cost The only costs to the Agency

are those costs associated with analysis of the reported information. The EPA compliance an d enforcement program includes activities such as the examination of records maintained by the respondents, periodic inspection of sources of emissions, and the publication and distribution of collected information. The average annual Agency cost during the three years of the I CR is estimated to be $106,353. This cost is based on the average hourly labor rate as follows: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%) Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%) Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%) These rates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality

rates of pay . The rates have been increased by 60 percent to account for the benefit packages available to government employees
. Details upon which this estimate is based appear below in Table 2: Average Annual EPA Burden

– NESHAP for Off

- Site Waste and Recovery Operation s (40 CFR part 63, subpart DD) (Renewal)

. 6(d) Estimating the Respondent Universe and Total Burden and Costs Based on our research for this I CR, there are approximately 236 existing sources currently11

subject to the standard. It is estimated that no additional sources per year will become subject to the regulation in the next three years. Number of respondents is calculated using the following table which addresses the three ye ars covered by

this I CR. Number of Respondents

Year (A)

Number of New Respondents (B)

Number of Existing Respondents (C)

Number of Existing Respondents That Keep Records But Do Not Submit Reports (D)

Number of Existing Respondents That Are Also New Respondents (E)

Number of Respondents (E=A+B+C

- D)

1 0 236 0 0 236 2 0 236 0 0 236 3 0 236 0 0 236 Average 0 236 0 0 236 To avoid double

- counting respondents, column D is subtracted. As shown above, the average Number of Respondents over the three

- ye ar period of this I CR is 236. The total number of annual responses per year is calculated using the following table:

Respondent Universe and Number of Responses Per Year

Regulation Citation (A)

Average Number of New Respondents per Year (B)

Number of Reports for New Sources (C)

Number of Existing Respondents (D)

Number of Reports for Existing Sources (F)

Number of Respondents That Keep Records But Do Not Submit Reports (E)

Total Annual Respo nses = (AxB)+(CxD) +F

40 CFR part 63, subpart DD 0 0 236 3 0 708
The number of total respondents is 236. This represents the number of existing sources plus the number of new sources averaged over the three

- ye ar period (i.e., the total of the number of new respondents over the three

- ye ar period divided by three years). The number of Total Annual Responses is 708. This is the number in column E of the Respondent Universe and Number of Responses per Year table above. The total annual labor costs are $14 ,681,368. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

- NESHAP for Off

- Site Waste and Recovery Operations (40 CFR part 63, subpart DD) (Renewal)

.12

6(e) Bottom Line Burden Hours Burden Hours and Cost T ables The detailed bottom line burden hours and cost calculations for the respondents and the Agency are shown in Tables 1 and 2 (below), respectively, and summarized below. (i) Respondent Tally The total annual labor hours are 155,212. Details regarding these estimates may be found below in Table 1: Annual Respondent Burden and Cost

– NESHAP for Off

- Site Waste and Recovery Operations (40 CFR part 63, subpart DD) (Renewal) . Furthermore, the annual public reporting and recordkeeping burden for this co llection of information is estimated to average 219 hours per response. The total annual capital/startup and O&M costs to the regulated entity are $5,000 (rounded). The cost calculations are detailed in Section 6(c)(ii), Estimating Capital/Startup and Op eration and Maintenance Costs.

(ii) The Agency Tally The average annual Agency burden and cost over next three years is estimated to be 2,360 labor hours at a cost of $106,353. See below Table 2: Average Annual EPA Burden

– NESHAP for Off

- Site Waste an d Recovery Operations (40 CFR part 63, subpart DD) (Renewal)

. 6(f) Reasons for Change in Burden There is no change in the calculation methodology for labor hours in this I CR compared to the previous ICR. This is due to two considerations: ( 1) the regul ations have not changed over the past three years and are not anticipated to change over the next three years; and ( 2) the growth rate for the respondents is very low, negative or non

- existent. There is, however, an apparent increase of 906 hours in respo ndent labor hours, due to a math error in the previous I CR. Also, there is an increase in both Respondent and Agency costs resulting from labor rate increases from 2003 to 2009. In this ICR, the labor burden and cost calculations in Tables 1 and 2 of this I CR were expanded to include managerial and clerical labor rates, and the previous I CR only p rovided a technical labor rate for 2003. This IC R has been updated to present the most recent available labor rates for each of the three labor categories.
6 (g) Burden Statement The annual public reporting and recordkeeping burden for this collection of information is estimated to average 219 hours per response. Burden means the total time, effort, or financial resources expended by

persons to generate, mai ntain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verify ing inf ormation, processing and maintaining information, and disclosing and providing information;13

adjust the existing ways to comply with any previously

applicable instructions and requirements; train personnel to be able to respond to a collection of informatio n; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a valid OMB Control Number. The OMB Control Numbers for EPA regulations are listed at 40 CFR part 9 and 48 CFR chapter 15. To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any s uggested methods fo r minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this IC R under Docket ID Number EPA

- HQ

- OECA

- 2009

- 0534. An electronic version of the public docket is available at http://www.regul ations.gov/ which may be used to obtain a copy

of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically . When in the system , select “search,” then key in the docket ID number identified in this document. The documents are also available for public viewing at the Enforcement and Compliance Docket and In formation Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., N.W., Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566

- 17 44, and the telephone number for the docket center is (202) 566

- 1752. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, N.W., Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA

- HQ

- OECA

- 2009

- 0534 and OMB Control Number 2060

- 0313 in any correspondence. Part B of the Supporting Statement This part is not applicable because no statistical methods were used in collecting this in formation.Table 1: Annual Respondent Burden and Cost
- NESHAP for Off
- Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Renewal)

A B C D E F G H I

Reporting/Recordkeeping Requirements Hours/ Occurrence Occurrences/

Year Hours/Year

(C = A x B) Respondents/

Year Technical

Hours/Year (C*D) Managerial

Hours/Year (E*0.05) Clerical

Hours/Year (E*0.10) Total

Hours/Year (H=E+F+G) Total

Costs/Yeara 1. Applications N/A 2. Survey and Studies N/A Technology and Systems b 80 1 80 0 0 0 0 0 $0.00 4. Reporting Requirements New Sources A. Read Instructions b, c 4 1 4 0 0 0 0 0 $0.00 B. Required Activities Included in 5 C. Create Information Included in 5 D. Gather Existing Information b, d 8 1 8 0 0 0 0 0 $0.00 E. Write Reports Ini tial Notification Report b, e 1 1 1 0 0 0 0 0 $0.00 Performance Test Notification Report b, e 1 1 1 0 0 0 0 0 $0.00 Compliance Status Notification b, e 2 1 2 0 0 0 0 0 $0.00 Performance Test Reports b, e 8 1 8 0 0 0 0 0 $0.00 Startup/Shutdown/Malfunction Reports 2 1 2 236 410.43 20.52 41.04 472.00 $44,646.07 Semi-Annual Summary Report f 4 2 8 236 1,641.74 82.09 164.17 1,888.00 $178,584.28 Reporting Subtotal 2,360 $223,230 5. Recordkeeping Requirements A. Read Instructions b 8 1 8 0 0 0 0 0 $0.00 B. Plan Activities b 40 1 40 0 0 0 0 0 $0.00 C. Implementation Activities Determination Commercial Facilities g 2 260 520 118 53,356.52 2,667.83 5,335.65 61,360.00 $5,803,989.04 Other Facilities h 2 12 24 118 2,462.61 123.13 246.26 2,832.00 $267,876.42 b. Vapor Pressure Determination Commercial Facilities g 1 260 260 118 26,678.26 1,333.91 2,667.83 30,680.00 $2,901,994.52 Other Facilities h 1 12 12 118 1,231.30 61.57 123.13 1,416.00 $133,938.21 c. Control Equipment Visual Inspection Large Cover 0.25 10 2.5 236 513.04 25.65 51.30 590.00 $55,807.59 Small Cover 0.05 1000 50 236 10,260.87 513.04 1,026.09 11,800.00 $1,116,151.74 Closed Vent System 0.5 5 2.5 236 513.04 25.65 51.30 590.00 $55,807.59 d. Control Equipment Leak Monitoring Cover Vented to Control Device 1 5 5 236 1,026.09 51.30 102.61 1,180.00 $111,615.17 Closed Vent System 1 5 5 236 1,026.09 51.30 102.61 1,180.00 $111,615.17 e. Control Devices Performance Determination b 40 1 40 0 0 0 0 0 $0.00 Continuous Monitoring System 8 5 40 236 8,208.70 410.43 820.87 9,440.00 $892,921.3915 A B C D E F G H I

Reporting/Recordkeeping Requirements Hours/ Occurrence Occurrences/

Year Hours/Year

(C = A x B) Respondents/

Year Technical

Hours/Year (C*D) Managerial

Hours/Year (E*0.05) Clerical

Hours/Year (E*0.10) Total

Hours/Year (H=E+F+G) Total

Costs/Year

a f. LDAR Program Identify Affected Waste Streams b 40 1 40 0 0 0 0 0 $0.00 Perform Monitoring/Repair i 80 1 80 47 3,269.57 163.48 326.96 3,760.00 $355,655.13 D. Develop Record System b Control Equipment 16 1 16 0 0 0 0 0 $0.00 LDAR Program 40 1 40 0 0 0 0 0 $0.00 E. Time to Enter Information Cover Designsb 40 1 40 0 0 0 0 0 $0.00 Control Device Design b 40 1 40 0 0 0 0 0 $0.00 Control Equipment Testing b 1 1 1 0 0 0 0 0 $0.00 Control Equipment Inspections 1 1 1 236 205.22 10.26 20.52 236.00 $22,323.03 Control Equipment Monitoring 1 1 1 236 205.22 10.26 20.52 236.00 $22,323.03 Control Device CMS 1 52 52 236 10,671.30 533.57 1,067.13 12,272.00 $1,160,797.81 LDAR Program 4 16 64 47 2,615.65 130.78 261.57 3,008.00 $284,524.10 Off-Site Material Determinations 1 52 52 236 10,671.30 533.57 1,067.13 12,272.00 $1,160,797.81 F. Time to Train Personnel b Waste Determination Methods 40 1 40 0 0 0 0 0 $0.00 Monitoring 40 1 40 0 0 0 0 0 $0.00 LDAR Program 40 1 40 0 0 0 0 0 $0.00 G. Time for Audits N/A Recordkeeping Subtotal 152,852 $14,458,138 TOTAL ANNUAL BURDEN 155,212 $14,681,368 Assumptions: a) This ICR uses the following labor rates: Managerial $114.49 ($54.52 + 110%); Technical $98.20 ($46.76 + 110%); and Clerical $48.53 ($23.11 + 110%). T hese rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2009, “Table 2. Civilia n workers, by Occupational and Industry group.” The rates are from column 1, "Total compensation." The rates have been increased by 110 percent to account for the benefit packages available to those em ployed by private industry. This ICR assumes that Managerial hours are 5 percent of Technical hours, and Clerical hours are 10 percent of Technical hours. b) This activity is performed once during the year following promulgation of the rule. c) It is assumed that it will take four hours to read instructions

. d) It is assumed that it will take eight hours to gather existing information. e) It is assumed that there will be no new sources. f) The burden of one annual summary report was included in the burden estimate for the semiannual report. g) It is assumed that at 50 percent of the facilities, the owner or operator manages, for a fee, off

- site materials received from other generators. h) It is assumed that 50 percent of the owners or operators accept the off

- site material at another location and ship it to the facility for storage, treatment, or disposal. i) It is assumed that 20 percent of 236 facilities will perform monitoring/repair.16 Table 2: Average Annual EPA Burden
- NESHAP for Off
- Site Waste and Recovery Operations (40 CFR Part 63, Subpart DD) (Ren ewal)
(A) (B) (C) (D) (E) (F) (G) (H) (I)

Activity EPA Hours/ Occurrence Occurrences/

Plant/Year EPA

Hours/Year (C=A*B) Plants/

Year Technical

Hours/Year (C*D) Managerial

Hours/Year (E*0.05) Clerical

Hours/Year (E*0.10) Total

Hours/Year (H=E+F+G) Total

Costs/Yeara Report Review New Plants b, c Initial Notification 2 1 2 0 0 0 0 0 $0 Performance Test Notification 1 1 1 0 0 0 0 0 $0 Compliance Status Notification 4 1 4 0 0 0 0 0 $0 Performance Test Reportd 16 1 16 0 0 0 0 0 $0 Existing Plants Startup/Shutdown Reporte 2 1 2 236 410.43 20.52 41.04 472.00 $21,270.58 Semi-Annual Summary Report f 4 2 8 236 1,641.74 82.09 164.17 1,888.00 $85,082.31 Report Review Subtotal 2,360 $106,353 TOTAL ANNUAL BURDEN 2,360 $106,353 Assumptions: a) This ICR uses the following labor rates: Managerial $62.27 (GS

- 13, Step 5, $38.92 + 60%); Technical $46.21 (GS

- 12, Step 1, $28.88 + 60%); and Clerical $25.01 (GS

- 6, Step 3, $15.63 + 60%). T hese r ates are from the Office of Personnel Management (OPM), 2010 General Schedule, which excludes locality rates of pay. The rat es have been increased by 60 percent to account for the benefit packages available to government employees. This ICR assumes that Clerical hours are 10 percent of Technical hours and Managerial hours are 5 percent of Technical hours. b) There will be no travel expenses associated with this ICR since we have assumed that no new sources will become subject to this rule over the three year period of this ICR. c) It is assumed that there will be no new sources (respondents) over the 3

- year period of this Information Collection Request. new or reconstructed turbines per year. d) It is assumed that it will take 16 hours to review each perfo rmance test report. e) It is estimated that the number of facilities subject to the rule is 236. f) It is assumed that two reports will be submitted by each of the 236 facilities on an annual basis.